A reasonable cause request for not filing 2016 and 2017 would definitely get rid of 10K of penalties.  The attorney thinks the request and the process of filing for reasonable cause would slow down the process and perhaps "throw a monkey wrench" in the process.  The executor could possibly be personally liable for the penalties incurred by this estate.  Since I am preparing the estate taxes, what is my role with respect to the executor?  He seems unfazed by the prospect of paying the penalties.